Blank Rome partner Anthony Rapa will serve as faculty for “Connected Vehicles Rule: New Auto Industry Supply Chain Compliance Requirements Could Signal More ICTS Actions Under Trump’s “America First” Policy,” a one-hour live online briefing being presented by Practising Law Institute (“PLI”) on Wednesday, May 7, 2025, from 1:00 to 2:00 p.m. EDT.
ABOUT THE PROGRAM
The U.S. Department of Commerce’s “connected vehicles” rule took effect on March 17, 2025, capping a rulemaking cycle under the Information and Communications Technology and Services (“ICTS”) regulations intended to address national security risks related to automotive connectivity. Specifically, the rule—developed during the Biden Administration and issued in the administration’s closing days—imposes import bans on connected vehicle hardware and on automobiles incorporating connected software where the connected technology was supplied or developed by China-linked companies.
The rule ushers in significant new compliance obligations for the auto industry, including a requirement for importers to submit to the U.S. Department of Commerce certificates of conformity that carries with it potentially stiff penalties for the furnishing of erroneous information. This requirement seems poised to trigger due diligence practices that will cascade throughout the automotive supply chain, as carmakers seek assurances that their vehicles’ connected hardware and software are free of China linkages that would give rise to an import ban.
Furthermore, it is important to consider the implementation of the “connected vehicles” rule in the broader context of the ICTS regime and the Trump Administration’s “America First” trade policy. Notably, President Trump’s “America First” trade policy memorandum specifically mentioned both the vehicles rule and the ICTS regulations as areas of national security focus for the administration and called for Commerce Department review of whether to expand the ICTS regulations to cover more connected products. This could signal a willingness for significant new actions in this area in the months and years ahead.
Topics will include:
- Introduction regarding ICTS / connected vehicles rule
- Background and overview of the ICTS rules
- Background and regulatory history of the “connected vehicles” rule
- “Connective vehicles” rule overview
- Select elements of the “connected vehicle” rule
- “America First” trade policy and ICTS implications
- Compliance tips
CLE credit is available.
To register or for more information, please visit the program webpage.
